Thursday, May 10, 2012

If I Won The NRC's $700 Million Dollar Reform Lottery

You know he is downplaying it...it is huge. And it's a spreading cancer on the nukes.

Exelon's CEO Mayo Shattuck:

"Even the existing fleet is feeling a little bit of the pressure in this kind of environment,” he said. The U.S. has 104 commercial operating reactors."

?
I would get the Allegation department outside the NRC...make them a stand alone entity.

 
US Senator Bernie Sanders and Vermont Attorney General William Sorrell to speak at rally to support Vermont.

April 6, 2012
Saturday, April 14, 2012, Noon to 2:00 pm
Brattleboro Common, Brattleboro, Vermont 05301
(rain location: Brattleboro Union High School)
statements issued day-of from
Governor Peter Shumlin and
Former Governor Madeline Kunin
and other elected officials
Special Musical Guest:
Fenibo (a rousing 12-piece Afro-beat ensemble
1) April 2, 2012

...I have spent an enormous of time talking to NRC officials and local NRC plant inspectors over the last year at VY, Palisades and Peach Bottom nuclear plant. I've submitted many 2.206s. A lot of NRC officials know my name and have spoken with me over the phone and in person.

If you really wanted to help me and the nation...you would help me reform the NRC's 2.206 petition process.

The below is in a condensed from...it designed to protect careers. It is in a nuclear industry technical lingo-speak that the NRC understands. They know these people are Root Cause Analysis professionals and have broad vision over many plants.

I am absolutely certain we have understated the problem. I am certain if this was investigated and mandatory testimony...we could prevent a lot of trouble.

Remember, I think they think doing a RCA gives factual ammunition to the NRC and in pending regulatory or court proceedings.

My blog: 'The Popperville Town Hall'


http://steamshovel2002.blogspot.com/

What we are talking about here in broad terms: it is the immune system of every nuclear plant in the nation and the nuclear industry.

...Of course, taking out the NRC Allegations section and the 2.206 petition process, that is call being in heaven.

I would want the NRC to be in partnership with me, not as a hyper rules based prosecutor or judge where I have no chance of ever getting past this corporate sponsored rules mandated to the NRC. I got to go up against this highly legalistic system even when it not really designed to be that way, where it is mostly laissez-faire and voluntary rules to a nuclear power plant. It is a check valve regulator!

They got a tons of laws and tools that limits my transparency to the problems of a plant and the agency; with very limited rules that mandates transparency to the public or me.

It is like a one way check valve on a host of issues, very little is spun my way in the interest of the USA (public), the vast majority are spun in the industry direction.

The overriding issue here is transparency and truth telling...the single most important determinate to nuclear and public safety is the nuclear industry showing their cards.

These guys got a lot of incentives to take shortcuts!

I won't bug you any more unless you ask for advice.

...Honest to god last time:

When I go through these NRC government processes...the 2.206 and Allegations...I feel it as the government is in a word, language, rules and process war with me. My government is at war against me and is using language as a weapon of war to me. It is not as a tool of understanding the issue or me. They become a understanding disruptor weapon.

A nuclear plant is so engineering, technically and organizationally complex...interacting with the NRC is 1000 times more complex.

I really need a seasoned senior NRC official who has seen everything and he has the horsepower to know the system and demand transparency. He needs to be assigned to me like my advocator and lawyer...his job is temporarily serve me and my issue ...to guide me through the agency's complex processes. All us outsiders need this kind of help.

I met and talked to a lot of NRC officials. Most of them are kind and decent when you get them by themselves. Most of them make us proud.

2) April 4, 2012

To who it may concern:

I can't believe I am doing this after having such a painful outcome talking to NRC Region 1 Allegation officials just a few days ago. I told myself I would never talk to Allegations again. If you want to talk to me I suggest it be outside Region I Allegations and preferably somebody from headquarters. I know there are lots more experienced people in the NRC than what I was recently exposed too.

I consider Region 1 Allegations compromised much like the March 2007 Peach Bottom sleeping guard incident where Allegations needed 500% absolute perfect inside evidence that was never obtainable in our existence. The NRC was too lazy to go down to Peach Bottom to investigate it on their own and they took the false assurances of Peach Bottom that there was no sleeping guards until the inside video came out that shook up the nation.


I consider the below a "cry for help" to me from multiple plant high nuclear employees and nuclear safety officials. And I certainly assert my confidentiality rights with this because this is so explosive to many careers. Nuclear Industry safety consultants might become blacklist from the nuclear industry. It exemplifies a pervasive of "I don't care" nuclear safety attitude throughout the nuclear industry. And these utilities are disrespectful to nuclear safety oversight in general.

I bet we are painting the most accurate leading indicator the NRC has seen in decades and we know the industry is in deep troubles as seen with all of your issues in recent years. These guys got a attitude problem and so doesn't the NRC!

I wish you would send a copy of this to the OIG?

 
...So is this about the reforming NRC Allegation process or RCA?

 Just kidding, or not.

 I kinda open here with my time. I could converse with you with within 24 hours, say tomorrow morning or beyond. I am good with before the end of the week, but I understand you people are busier than me.

What the hell does "specific information" mean?

 
...3:00pm on 4/10 is a excellent choice.

 By the way, what are my needs that enables the exercises of my democratic Constitutional ideals or rights with the agency's rules.

1) Full access to the target site, documents and employees of a nuclear power plant or NRC.

2) My sufficient funding, skills and education to do my own independent investigation to give the agency its rule enabler.

"Specific information (e.g., which site/plant, organization, personnel) is necessary, for the NRC to respond to any issues, which are raised by concerned citizens."

...Really, I am a ant...you would need a sufficient independent "organization" with sufficient uncontested access, resources and intellectual horsepower, which could counteract or challenge the Republican ideological influences over of the agency and the influences of the cohesive nuclear industry and their owners.

It should neither be pro nuke or anti nuke...just hunting for the truth!

You would need a transformational organization...

Wednesday, April 11, 2012

American Tissue Corp

American Tissue Corporation
I would gladly talk to people about my activities concerning American Tissue corp to any legitimate people. It is a fascinating story. I bankrupted the 4th largest paper mill company in the USA and this lead to putting executives in jail.

It was a fascinating learning experience for me. It was a $300 to $400 million dollar fraud case. It was a warning to us about the upcoming financial crisis we ignored.

Wednesday, March 28, 2012

Pilgrim's failed Target Rock SRV

New April 5, 2:30pm
The OIG gave me a call today.

...He humiliated and disrespected me with this phrase " if your were a decent whistleblower" you would have a complete report.

You know what I say, record and transcript every conversation I have with NRC official. If you were with me on my conversation you would see how disgraceful and uneducated some officials are.

Mostly the front line NRC inspectors and their bosses are really decent people...but the support people like Allegation and the OIG are atrocious and with their knowledge of the nuclear industry. They generally don't have the skills and are not trained to talk in a non threatening manner and have a open discussion.

This guy began exactly like the Allegation...what was the LER nmber?
  
...So were talking about target rock and why components immediately failed on new installs.

This guys didn't know what a safety relief valve did in a BRW. I had to educate him on its function.

You know what, these are really complicated components and organizational issues. You just can't come into a conversation with me without deeply researching my issues or I have to give you grammar school class in BWR designs. Both Allegation and the OIG did this.

If you don't do your background work before you get to me...i am going to lose you within the first five minutes.

The NRC OIG guy said its not fraud waste, misconduct or abuse within the rules of the OIG...so it a licensing or NRR thing. I said believe me i got it with your NRC people, you are going to pass me from one department to another because some NRC employees are too lazy to do their jobs. I am going to have to explain myself 100 times to different departments and NRC employees, who don't even know what the function of a SRV is. 
...The NRC is doing one of those teenager la la la la deals while covering their ears to the obvious.

Basically, I asserted LER's are insanely incomplete and inaccurate...

...I would say i was exposed to a militaristic use of language to disrupt communications....the use of rules and regulations in way to disrupt communication and knowledge of the problem to the
public. It is using words, language, rules and regulations, indeed government as weapons against the innocence...the intent is deny public participation with government. They militaristically trying to rule me and everyone out of public participation.

I think what we got here is systemic breakdown with the utilities and NRC to control vender repair, new parts and basic off site engineering services. I think these vendor component and engineering suppliers are not required to tell the truth. I would say since I been hitting them on these issues the NRC has tried to come to grips with their vender service provider problem.

Bottom line, they are having trouble getting replacement parts on these obsolete plants. Companies have gone out of business and ceased production streams, and the new deal is they are hiring companies who specialize in doing "reverse engineering" on replacement parts that are dangling without any new parts stream.

...As example, all the new Mitsubishi kids are making the San Onophe SGs and the old experienced engineers have retired or died.  


New March 28
I backed out of the NRC allegation process. They got hyper legalistic and evidence thingy on me...they knowing that the agency and the utility had all the cards. I said the Peach Bottom 2.206 administrator sent my issue into allegation...I didn't call in allegation on my own. I thought it was going to be a conversation between me and agency...not this one way deal where if i said i sneezed then I had to prove I sneeze. I asked, should I have brought my lawyers and engineers into the deal.

I didn't think the Allegations process was fair and opened...it was hyper legalistic and hyper regulatory rules thingy where you couldn't sneeze if it wasn't in the rules. The Alligation team went cold into this not even researching my involvement with VY and Peach Bottom, and the LERs and inspection reports.   

I said I withdrawal my concern and I don't want to be updated about this. They told me you can't withdrawal a concern once one was given to the NRC....but you can be anonymous.

  ...At the bottom of it over VY and the Peach Bottom SRV issue, I spent days researching everything i could about the SRVs. I spent a hour and half each with both inspectors at VY and Peach Bottom for a total of four plant inspectors and three hours talking to me. I knew the territory and what I was talking about...I was frustrated that these four officials went cold into this meeting. Then they played the, mike this thing is evidence driven and we got to know the LER number and we got to know who the VY inspector's names are. It was humiliating and disrespectful for me. There was one official talking to me as I was discussing my issue, then none of the other three officials could even do quick search on the VY docket for the LER document number to get us past the sticking point. What BS!

I got a e-mail trail from Don, lets schedule a meeting beginning last thurs. I say I ready right now, tomorrow and any time at your convenience next week. Just set the time and date and i will be there. I wanted to make it easy for him. Then I get a e-mail tues saying I can't find anyone to have a meeting with you without any explanation. Next day he tells me the following day the meeting is on, what time.

They don't even have the courtesy on their own to read my 2.206s and transcripts surrounding the VY and Peach Bottom seals. These Allegation idiots have in their documents I make a recent allegation by phone about VY seals again and they are the ones who made the VY inspectors call me without going though the Allegation process.

That is another more specfic information not disclosed in the VY LERs or inspection reports...the 400 degree vitol seals.


We should go through the VY seal LER and update, then contrast what got in the NRC inspector report and then what came out in the NRC inspectors meeting with me. We should then discuss what should have been disclosed in LERs and further inspection reports. As far as i am concerned, the inspectors at both plants should be on the phone bridge. We should go over it point by point and not have any other commitment to rush anyone, until everything is completely hashed out. We should do the same thing with the Peach Bottom LER.

Again, we don't have public participation with the NRC and utilities around our homes, unless all the aspects of the problem is out in the public arena.





March27 

Mr. Mulligan:
I have been unable to contact the appropriate NRC technical staff, for a telephone call with you. I will contact you when I know more.
Sorry for the late information.
v/r,
Ron Schmitt
USNRC

New




From: "Schmitt, Ronald"
To: "Michael Mulligan (steamshovel2002@yahoo.com)"
Cc: "James, Lois"
Sent: Thursday, March 22, 2012 8:33 AM
Subject: Time to discuss your concerns (RE: Quality Assurance program at Target Rock)
  

Dear Mr. Mulligan:
This email is in regards to your email that you sent to Mr. John Hughey, of the U.S. Nuclear Regulatory Commission (NRC) on March 17, 2012. In your email, you expressed concerns regarding the Quality Assurance program at Target Rock, as a result of failed safety relief valves at Vermont Yankee, Pilgrim and Peach Bottom nuclear power plants.
We would like to set up a call with you so that our staff can ask additional questions to better understand your concern.

Please respond to this email with some days and times that are convenient for you so that I can schedule the call.
Thank you for informing us of your concern. If you have any questions, please contact me or Ms. Lois James at .
 
Ronald V. Schmitt
Office Allegation Coordinator
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission

Pilgrim's failed Target Rock SRV
Licensee Event Report 2011-007-00: Safety Relief Valve leakage

So you get it, with the SRV threaded seals at VY and Peach Bottom they failed within the first cycle from degradation due to poor quality seals. Now at Pilgrim another SRV fails with months due to leakage and they blame poor pilot valve workmanship at Target Rock.

Sounds like systemic QA problems with Target Rock. I request a investigation of Target Rock and all similar safety valves.


I talked to your nice Peach Bottom inspectors over increasing the SRV's set inaccuracy from plus or minus 1% to plus or minus 3%. Does the NRC have any evidence that decreasing the margin of set point accuracy reduces the entry into applicable tech spec LCO. I see all the utilities have different guesses on what cause pilot valve bonding. Some say its oxygen or hydrogen that sets up bonding on the surfaces, others say its just bonding and they don't care. Others again say its outside insulation and temperatures that sets it up.

As far as the statement that increasing the relief valve testing set point inaccuracy will reduce entry into a LCO, I don't think that is true. The limited data I see indicates when you increase testing set point inaccuracy, you increase entry into a LCO in the long run.


PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION


October 1, 2011 through December 31 , 2011

 The inspectors selected the issues of safety relief valve (SRV) and automatic depressurization system (ADS) valve leakage and setpoint test failures as an inspection sample for in-depth review to assess the corrective actions taken by Entergy to address these long-standing issues. Entergy's corrective actions included replacing the four ADS valves and the two safety relief valves with a Target Rock three-stage relief valve design, increasing the capacity of the two safety relief valves, and amending the license to allow for a set-point pressure band of +/- 3%. Additionally, the new valves were equipped with multiple leak detection temperature indicators.

The inspectors reviewed procedures, condition reports, engineering evaluations, modification packages, post maintenance testing, and license amendment correspondence, and interviewed plant personnel to assess Entergy's problem identification, evaluation, and corrective action effectiveness with respect to SRV and ADS valve leakage and set-point drift. Additionally, the inspectors reviewed the technical specifications and UFSAR to assess the change to the relief valves with respect to design and licensing bases requirements. Documents reviewed are listed in the attachment. Findinqs and Observations

Findinqs and Observations
No findings were identified.

The ADS valves and SRVs were originally a two-stage Target Rock-type design, consisting of a pilot-stage assembly and a main-stage assembly. Industry Operating Experience had shown that two-stage Target Rock relief valves exhibited some amount of pilot-stage leakage during plant operation. Additionally, the technical specification allowed valve setpoint pressure band was +/- 1%, which left little margin to maintain the valves operable in the event of valve leakage. As a result, SRV and ADS valve pilot stage leakage were challenges throughout the plant's operating history and caused several forced shutdowns.

The inspectors noted, based on nuclear industry operating experience, that the replacement of all the ADS and SRVs with the three-stage Target Rock design was a significant positive step in reducing the likelihood of relief valve seat leakage.

Additionally, the inspectors noted Entergy's evaluation of an expanded relief valve setpoint pressure band and subsequent license amendment have resulted in significantly more operating margin for the plant in the event that a valve does exhibit signs of leakage. Finally, the inspectors determined the addition of several temperature monitoring points on the valve would allow Entergy to more effectively evaluate the operability of the valve should any leakage occur.

Monday, March 26, 2012

Mike Mulligan's US Government Renaissance

First published as comments in the NYT's in: The Nurture of Nuclear Power

I always thought the problem with nuclear power was ideology not technology. The dominant control ideology of the industry has been increasingly the hard right wing conservatives and this ideology is dominant at every plant. There are very few democrats at any of these plants and certainly even less as you go up the management ranks.

The model has defaulted into a autocratic and a decentralized form...every plant is a one off. We serve profits and self interest, and not the greater good of our nation.

The true benefits of nuclear industry has never been shown. I propose a government take-over of the 25 Fukushima plants in the USA. As a national security issue, we should replace those plants with brand new identical models. Lets begin another grand experiment. They would be large plants and centrally controlled in the initial construction and early operation phase. Imagine the efficiency if these plants were built to one set of codes from both the regulator and the designer/builder stand point. It should be a government controlled and modeled like the TVA project.

What if we woke up one day and we discovered government could be more efficient and 'just' than any corporation...or at least could complete with them.

President Obama could say these plants are a dire threat to the USA and the only way out is to replace them. We just about got negative interest rates with QE2 and why couldn't we come up with a revolutionary borrowing mechanism. It would be a giant jobs and public works project. It would split the Republicans this fall and who knows the size of the political coalition we could create for the nation?

There is more value than the traditional economic benefits than cheap and reliable electricity over a project like this. We should value a project like this for how much advanced education and advance managerial experience it drives into our nation. How much advanced intellectual experienced it drives into all the employees who are associated with this voyage. This is, and always was, the real wealth of our nation!

Wednesday, March 21, 2012

An Unforgettable Night - ATC Operator Event at Palisades

There are a lot of these CRDM seal shutdowns at Palisades. No other plant in the nation has these kinds on troubles. These complex seal repair shutdowns have been involved with unpredictable interactions and incidences.

A initial plant design defect that is not corrected is driving enormous complicity into the control room and their employees are being overwhelmed by it.

I told the NRC this was a very important event for the industry and there should have been reports to the industry about what went on this night a Palisades. What nobody can get away from, the agency doesn't have the capability to capture events in such detail as this employee did.

This event occurred on Oct 23, 2010 and Palisades has had another seal shutdown on Jan of this year. We got to see this letter for the first time this March 8 2012.

I believe the event was entered into the Palisades ROP as a question of why did one of their employees leave the control room. Nobody has yet answered why were they winging this vacuum fill procedure, why did they lose reactor water level for a period of time worrying about vortexing and why did they allow so many distraction going on while they were manipulating core water level during a high risk alignment of the plant.



An Unforgettable Night - ATC Operator Event at Palisades

Introduction
On the early morning of October 23, 2010, I left the ‘at the controls’ area of Palisades nuclear plant without a proper relief or turnover. Up until that time, I had always considered myself to be a very conscientious and safe operator. I never imagined that I would leave the control room without a proper turnover – but I did. I hope by writing this article, others can learn from my mistakes and avoid making the same or any similar mistake. With that objective, this article describes the events that led to my actions, the effect this event has had on me, the lessons I have learned, and my experiences with the NRC investigative and enforcement processes.

Description of Events
Palisades was nearing the end of a refueling outage, which was on course to be our most successful ever due to the short duration and large number of major projects completed. We were about to enter our third reduced inventory period to perform a vacuum fill operation.

This vacuum fill procedure was relatively new for Palisades, having successfully

performed it for the first time during the previous refueling outage. It is a procedure to lower the water level in the reactor to the middle of the hot leg, and then draw a vacuum on the Primary Coolant System (PCS) to evacuate air and other non-condensable gasses. We devised this procedure in an effort to improve plant reliability—specifically to extend the life of our control rod drive mechanism pressure boundary seals.

Excerpts:

During the brief, I mentioned that during my turnover briefing, I heard that the reactor head did not have a vent path.

We lined up the drain path and commenced, but the PCS level indications did not respond as expected and we stopped the drain.

During this period, we had Auxiliary (non-licensed) Operators (AO's) troubleshoot the problem by verifying level glass and vent path lineups.

Concurrent with the PCS drain, most of the control room staff was at the Infrequently Performed Test and Evolutions (IPTE) brief for the vacuum fill work.

While this occurred, we had more issues with the EHC system; a reactor operator called the control room and stated he was not sure we had a good EHC flow path.

I felt this was a problem that required reviewing the prints and was too distracting with the PCS drain taking place while in reduced inventory, so I handed off the call to a different operator.

I told a Senior Reactor Operator that we were having issues with the EHC system, but he was busy overseeing the PCS drain.

A few moments later, however, the EHC low level alarm came in.

Several minutes later, the low level alarm was still not clear and I was concerned about a possible leak, so I secured the pump. I quickly heard back that there was a spill...

Consequently, they requested that the pump be placed in service for their vendor work, stating the cooling and flow path issues were solved.

This was all happening while the PCS level indication troubleshooting was in progress.

Eventually, Maintenance workers removed some temporary flange covers on the reactor head for a better vent path.

The drain that we initially briefed to be about 17 minutes ended up taking over three hours.

After we got to mid-loop, I lowered shutdown cooling flow to about 3100 gpm, which was the high end of the vacuum fill requirements.

...commented that he did not like the pace I was making my adjustments.

The previous time we performed the vacuum fill procedure, it worked flawlessly, but this time was different.

There was indication of a leak somewhere that was intermittently venting and allowing pressures to equalize throughout the system.

While Operator 1 and other members of the control room staff were troubleshooting the problems with vacuum fill, we received the low critical service water alarms and entered a procedure for "Loss of Service Water."

...the Control Room Supervisor (CRS) had to come down off the CRS’ “island” and speak with me directly to ensure effective communications during this very active period in the control room.

We soon learned that the work control center sent out a lube and stroke PM for the main lube oil service water isolations, and that was probably the cause of the low header pressure.

During the hold, I noticed the shutdown cooling flow rate had slowly started to trend down to 2900 gpm on its own and I voiced my concerns to the Control Room Supervisor. I showed him the one minute shutdown cooling flow rate trend on the Palisades Plant Computer (PPC), and said there may be some vortexing or other flow phenomenon that I did not understand.

He stated we could also enter the LCO, if necessary.

Suddenly, however, PCS level indication sharply fell to an elevation below the bottom of the hot leg.

As PCS pressure rose, the primary coolant level slowly recovered to an expected value and I received the order to raise the PCS level to exit reduced inventory.

By this time, it was early morning and we exited reduced inventory during SRO turnover.

Thursday, March 01, 2012

Byron Switchyard Insulator 2.206


So what would prevent all the defective switchyard insulators from breaking and shorting in a heavy storm, tornado or earthquake and then causing another LOOP...

The last LOOP at the plant was extraordenary, in that the plant was disconnected from grid for 31 hours. LOOPs are generially 1,2 to less than 4 hours duration.

March 20:

Exelon upgrades equipment at Byron nuclear plant

The Associated Press

BYRON, Ill. -- Exelon Energy says it has finished upgrading equipment at a northern Illinois nuclear plant where a power failure caused a reactor to shut down two months ago.
The company says it has replaced electrical insulators in the switchyards that help move power to and from the reactors at the Byron Generating Station, which is located about 95 miles northwest of Chicago.
In January, an insulator in Unit 2 switchyard failed and interrupted power, causing the reactor to automatically shut down as a precaution.
Insulators are protective equipment that helps regulate the flow of electricity. Exelon says Unit 1 was taken offline last week while upgrades were finished, and Unit 2 upgrades were finished over the weekend. Both units are back online at full power and generating electricity.

Read more here: http://www.bnd.com/2012/03/20/2107206/exelon-upgrades-equipment-at-byron.html#storylink=cpy

Saturday, February 18, 2012

Vermont's Appeal over VY

Interesting, the chairman posed the same question I did but in a more delicate manner...
Gregory B. Jaczko: "Looking to the Future”

February 9, 2012
"So the question is: what does that tell us about the use of risk? Is it an effective metric? To some extent one could argue that based on the risk models, accidents like Fukushima will happen -- hopefully with a very unlikely or low frequency, but they will happen -- and they are acceptable. They are well within our risk metrics, primarily because we ultimately had a robust system that allowed people to be evacuated and allowed ultimately for people to be relocated from any exposure to radiation.

Now, I think if I were to talk to an average person on the street and say that, people would say no, that was a pretty significant event. And I personally think that's right. I think that this was a significant event, and it was an unacceptable event. But if we look at the risk models that we use today, it is not -- in our risk model -- an unacceptable event."


Feb 18:
I also spoke, "imagine if we had a core meltdown without fatality in a severe accident in the USA. You people discount this, only consider a nuclear fatality. A nuclear accident with fatality is just marginally worst than a no fatality.

At Peach Bottom, it would destroy two plants because they are so close to each other even if the other one wasn't damaged. It would destroy the value of the largest utility in the USA. There would be massive investigations. What was once thought of as accepted behavior would be thought as gross negligence and a cover-up for decades. I am certain the investigation would rip the lid off the NRC and the whole industry...what other plants are threatened. Certainly the NRC losing their credibility and trust would be a accident in itself.

Remember, we have only had a meltdown in the pre internet period and pre social media interconnectivity period. TMI would be a drastically different accident in this social media and self publishing world....nobody could control the political fallout from this. It would cascade until the energy was spent. And Fukushima got us all teed up already....

Who knows what this stock and debt panic would do to the utilities in the outcome in the meltdown without fatality. That is 20% of our electricity, its a enormous amount of electricity and irreplaceable out for a decade or two. We'd have massive speculation, price spikes and shortages for a far as you can see. It would be disruptive to the whole nation. It would be disruptive to our political system. I am talking about a catastrophe of epic proportions for our electric system.

On a planetary level, the USA would be a nuclear technology disgrace...who knows how many plants would get kicked off the line. Our national stature and credibility would be threatened. Depending what they find under the sheets, we might even get a new president...it might just throw the election. You know everyone would play political football with this. Can you imagine the world we would live in if the antis had a current meltdown as ammo?  

Feb 17 (Reuters) - Vermont's Attorney General appealed on Saturday a federal judge's ruling that had prevented the state from shutting down its only nuclear power plant, escalating a two-year battle over state's rights and atomic energy.

Was that pretty neat yesterday in the 2.206 proceeding inviting all the NRC and Exelon employees to watch the Sunday CCN special about the NRC and VY...

Wasn't that neat when i said to them, "does anyone think this is a coincidence that I on am on a phone in my house and I got all you people in your offices listening to me today, and you got a CNN special about Vermont Yankee later this weekend. Does anyone not believe this was intentioned this way?

Then I give them my rendition of the Vermont Yankee problem..."it is excuses over and over again of the NRC and utilities with intentionally turning your heads away from immediately addressing and fixing known problems in the industry"...

Monday, February 13, 2012

NRC’s OIG: Confirmatory Action Letters



Feb 15: Yep, you got to wonder if the NRC OIG initiated the CAL investigation after reading my Casablanca-Palisades 2.206 on Feb 22, 2011... The NRC says the investigation started 9 months ago?

You notice I stayed with the themes of the Casablanca 2.206 on my newest 'Nothing Ever Matters-Palisades' 2.206.     


OIG-12-A-09 February 10, 2012

Audit of NRC’s Use of Confirmatory Action Letters

I think they got a lot of neat tools, but the NRC doesn't have the skills and training in order to properly and effectively use these neat tools. You catch the similarities with the OIG event reporting...mass confusion with contradictory NRC policies. Can you imagine all the confirmatory Actions letters awarded to Palisades and Entergy...and why are they so ineffective with getting a change of heart out of Entergy?  

    Jan 10, 2012: Request Emergency Palisades Shutdown

    "We are broadly worried about in 2009 over the Palisades security falsification, in the outcome of the violations...whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over this very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip, the most recent root cause Entergy admits there is deep and widespread safety cultural problems at the Palisades plant. I feel Palisades safety culture was in the pits in 2009 and before...and the cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution secession over this, the Confirmatory Order, the Entergy investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy...the NRC created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them. Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public’s eyes off fixing Entergy...where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up."
Audit of NRC's Implementation of 10 CFR Part 21, Reporting of Defects and Noncompliance OIG-11-A-08 March 23, 2011 "NRC Regulations and Guidance for Implementing Section 206 Are Contradictory and Unclear

Part 21 component defect reporting issues exist because NRC regulations and guidance for implementing Section 206 are contradictory and unclear. Specifically, NRC regulations and guidance for implementing Section 206 contain stipulations that have been interpreted as not requiring a report under Part 21 if an LER was not required. This interpretation seemingly contradicts Section 206, which requires reporting of component defects that could cause substantial safety hazards. Furthermore, applicable NRC reportability guidance is not utilized by some licensees and NRC staff, and NRC’s Baseline Inspection Program does not include requirements to inspect licensee reporting of Part 21 defects."
Transcripts 2.206 Petition Review Board RE Palisades Nuclear Plant dated January 31, 2012
"And like I said, you know, we can -- all this survey -- cultural survey stuff, you know, words have meaning, and results having meaning and stuff. And that was inaccurate, that survey stuff was inaccurate. And it's a con job because, essentially, Entergy gets to hire their own people. And they probably tell the companies beforehand this is what we want, can you do it for us? And that's what they get.

You know, I don't know. Maybe the NRC ought to hire somebody independent or something like -- I don't know what the question is but, you know, that was -- we could have -- Entergy should have found the problem two years ago and they didn't.

The problem is they go through another ADR process. It began in 2010. It just came out as an enforcement finding with the employee that stormed out of the control room. Basically, the same thing is --another agreement. This thing isn't, you know --Entergy, you do it or stay shut down. This is another-- you know, a gentleman agreement, essentially -- I can't even say the word, confirmaternity [confirmatory action] letter, whatever you call it.

How many (confirmatory action letters) has Entergy had in the last few years --two or three at Palisades, and who knows what they've gotten over the fleet. I mean, how well does that work and stuff? So, you know, so another survey is going to be, done fleet-wide, more fleet training. These poor guys they're getting overwhelmed with all the fleet training on integrity and stuff. You know, it just bothers me that this thing wasn't prevented." 
US nuclear watchdog questions oversight of safety enforcement

By M. Alex Johnson, msnbc.com

The federal government's nuclear watchdog has faulted the Nuclear Regulatory Commission for failing to follow through on safety agreements with nuclear facilities, saying its system for tracking corrective action raises questions about its oversight of nuclear safety and security.

After an eight-month audit, the NRC's Office of Inspector General concluded last week that the commission has no centralized way to oversee or follow up on documents confirming that a nuclear facility has committed itself to address "significant concerns regarding health and safety, the environment, safeguards or security."

The documents — known as Confirmatory Action Letters, or CALs — are one of the last measures before the NRC cracks down with a stringent binding order like suspension or revocation of a nuclear plant's license.

Because CALs are reserved for a small number of potentially serious cases — 15 to 20 of the hundreds of incident reports the NRC issues each year, according to its records — effective oversight of the confirmation process is of "utmost importance," the inspector general said. But in some cases, the action letters are so poorly drafted that they don't even make it clear who the intended recipients are, the report asserts.

Bureaucracy to blame


The problem is one of red tape, not willful inaction or neglect, the report says. But the weaknesses — which include lack of consistent guidelines for regional NRC offices, regional offices' failure to comply with those guidelines and some offices' lack of any tracking system whatsoever — "degrade" the agency's accountability, it says.

 A spokesman for the NRC said the agency believes "the CAL process has been effective" and that it would have a formal reply "in the near future." In an informal meeting last month, the NRC generally agreed with the inspector general's recommendations to update its main enforcement manual, centralize tracking and submit to occasional audits of the action letter system, the report said.

Wednesday, February 01, 2012

Peach Bottom SRV Seal notes


Feb 21
Oversight of Nuclear Reactor Suppliers

See, they don't have broadly the proper quality framework to maintain standards...either operating and new.

Like I said, the NRC doesn't have the power or know how to us power and coercion to maintain standards againt the corporate interest of making profits...

Somebody's got to be the bad guy...not a consensus maker?
Feb 17 (Reuters) - Vermont's Attorney General appealed on Saturday a federal judge's ruling that had prevented the state from shutting down its only nuclear power plant, escalating a two-year battle over state's rights and atomic energy.
Was that pretty neat yesterday in the 2.206 proceeding inviting all the NRC and Exelon employees to watch the Sunday CCN special about the NRC and VY...

Wasn't that neat when i said to them, "does anyone think this is a coincidence that I on am on a phone in my house and I got all you people in your offices listening to me today, and you got a CNN special about Vermont Yankee later this weekend. Does anyone not believe this was intentioned this way?

Then I give them my rendition of the Vermont Yankee problem..."it is excuses over and over again of the NRC and utilities with intentionally turning your heads away from immediately addressing and fixing known problems in the industry"...


Main Steam Safety Relief Valves Buna-N thread seals (March17, 2002)

You like that picture, these electrical towers are what the back-up to the back-up Fukushima emergency supply of electricity get supplied to VY through...

First Transcripts

Second Transcripts
Some commonalities with the SRV seals

1) Buna-n.

2) Both facilities when they got new actuators ...during the next cycle their buna-n failed. VY had multiple seal failures after new actuators and Peach Bottom's seal failure came after they were just installed.

3) As a thumb rules, you can't trust the quality of buna-n material after 2002.

Mr Mulligan

I have also spoken with the Peach Bottom Resident Inspectors regarding your request to discuss the Peach Bottom safety relief valve (SRV) seal failure history with them prior to the PRB teleconference. The Senior Resident Inspector, Sam Hansell, and Resident Inspector, Adam Ziedonis, would be happy to speak with you. You can contact them directly at 717-456-7614.
The PRB met internally on February 3, 2012, and denied the request for immediate action to shutdown Peach Bottom Units 2 and 3, and replace the SRV pneumatic actuator threaded seals, because there was no immediate safety concern to the plant, or to the health and safety of the public. Specifically, the PRB determined that threaded seals with Buna-N material have been used in the PBAPS Unit 2 and 3 SRVs for 20 years with no seal failures until the subject failure in September 2011. The 3-ADS-SRV 71B seal had been in service for less than one year before its failure and the seals are replaced every 4 years. In addition, the insulation configuration on the Vermont Yankee SRVs that contributed to their 2 seal failures was confirmed to not be a contributing cause for the PBAPS Unit 3 ADS-SRV 71B failure. These facts support the conclusion that the failure of the 3-ADS-SRV 71B threaded seal was not a common mode failure, or an age related failure, but was isolated to the particular seal installed in the 3-ADS-SRV 71B actuator in November 2010. This information will be included in a future NRC Inspection Report regarding the subject SRV threaded seal failure.
Thank you,
John Hughey
Peach Bottom Project Manager
NRR / Division of Operating Reactor Licensing
Phone: 301-415-3204

Friday, January 13, 2012

2.206 notes

New 1/31/2012

The big deal out of today is...type 416 ss is cheap metal. All the shafts are made out of 416 ss so why don't they have corrosions like the couplings.

It is shocking to me they are using type 416 on the shafts, as they changed out that material out the couplings...and the NRC and the Entergy never seemed to be worried about the shaft cracking....
Entergy's Root Cause Analysis

January 05, 2012
The three Service Water Pumps (SWPs), P-7A, P-7B, and P-7C, are modified Layne and Bowler pumps. They are comprised of a two stage pump end with stainless steel impellers connected to a discharge head by seven columns for a total height of over 40 feet from suction to discharge.

 
Lucius Pitkin , Inc . Consulting Engineers

METALLURGICAL AND FAILURE ANALYSIS OF
December, 2011
"P-7A and P-7C are Layne and Bowler Model 25RKHC pumps while P-7B is a Johnston Model 25NMC pump. Each pump is driven by a 350 horsepower (HP) motor providing a rated 8000 GPM at 140 ft total developed head (TDH), which is 50% of the service system capacity [1]."


NEW:
From: "Chawla, Mahesh"
To: Michael Mulligan ; Michael J Mulligan
Sent: Tuesday, January 24, 2012 2:45 PM
Subject: Palisades 2.206 Petition dated 1/10/2012 - Mike Mulligan
 
 
-->
Mr. Mulligan,
I have been assigned as the petition manager for your 2.206 petition which you submitted on January 10, 2012, requesting an emergency shutdown of Palisades Nuclear Plant. Since you submitted this as a 2.206 process requesting an immediate enforcement action, a Petition Review Board (PRB) was immediately formed.
The PRB met internally on January 19, 2012, and denied the request for immediate action because there was no immediate safety concern to plant, or to the health and safety of the public. Your request for the immediate action of shutdown of Palisades and other Entergy Plants did not have the adequate bases. You have cited numerous equipment failures and made accusations of falsification of records and also you find the ROP process to be inadequate. However, you did not provide any additional information for NRC to consider. The staff is well aware of the information you have provided in the petition and these issues/events are being handled by NRC processes.
The 2.206 process is a public process. The NRC normally makes 2.206 petitions publicly available (except for sensitive or security-related material). I believe you are familiar with our process, but please respond to this email and confirm with us by January 27, 2012, that you have no objection to participating in this public process, and allowing your petition to be made public.
Also, the PRB in the Office of Nuclear Reactor Regulation (NRR) will be reviewing your petition. We offer 2 possible meetings with the PRB. One can be before the PRB reviews your petition, in which you or your representatives have the opportunity to provide any relevant information to the PRB. There will be a second opportunity to address the PRB following the PRB’s initial recommendation on whether or not to accept your petition for review. Please advise if you are interested in either one of these possible meetings. The meeting can be in person, at NRC headquarters in Rockville, MD, or by teleconference. These meetings are transcribed, and the transcript becomes part of the record. Please let me know if you wish to participate in either of these possible meetings.
Mahesh Chawla
Project Manager, NRR/DORL
U.S. Nuclear Regulatory Commission
301-415-8371
 
Entergy in their Root Cause said Palisades had three Layne and Bowler service water pumps. But they really have two of those 350 hp pumps and other is a Johnson model 25NMC pump.

...On the service water coupling, they talk of this repeated wetting and drying cycling that causing IGSSC...the on and off cycling of the pumps. It dries out in the thread crevice, 10ppm which is a really tiny amount of salt . The problem is, the c pump was on 92% of the time while the coupling failed the first time, then 87% of the time the second failure. You know, where is all this opportunity for all this wet/ drying cycling?

They got a little coupling drain hole right in the middle of the coupling. So the water goes in and out this little hole. You know, what the hell does that hole do when the shaft is spinning so fast , then what about all the flow going up the pump. There seems to be a lot of turbulence going on there. So why isn't all this turbulence flushing out all the tons of salt where the shafts meet.

 

 
...So i was asking why was hydro-aire trying to "reverse engineer" the modified Layne and Bowlers pumps couplings. I am confused, so the Layne and Bowler pump company hails from the great country of Turkey. Gets you to wonder where all the couplings were manufactured in?
Preliminary report shows Palisades among worst power plants in U.S.

Final report still in the works

"COVERT, Mich. - If a preliminary report by the Nuclear Regulatory Commission is made final, the Palisades Nuclear Power Plant, just north of Berrien County, will be one of the worst performing nuclear power plants in the country.

In 2011, Palisades shut down five times unexpectedly, caused three NRC violations, and required two special federal inspections within a month. “We saw a significant decline in the performance of this plant,” said Viktoria Mitlyng, an NRC spokesperson..."

In the last two months I have spend more time with Viktoria on the phone than I have been with my wife. It is clear she serves the NRC, we had disagreements...but I really like her.


Jan 18, 2012 Detroit Free Press Editorial

On Lake Michigan's shore, no room for lax nuclear safety

"Yet documents and testimony suggest that something as simple as changing a burned indicator light has resulted in cascading events; in the case of the light change last September, the plant ultimately shut down. It was one of at least five unplanned shutdowns in 2011."

It is interesting, anyone who has been watching this knows this sentence is utterly inaccurate. It goes to show, what is a huge factor with what causes a Palisades, is a utterly failed 4th estate.
 

...It is interesting, the Entergy root cause of the emergency airlock not working green light says they were doing trouble shooting (in sept 2011) of the failed light in anticipation of the up coming due surveillance of the airlock. As we know, the light went broke prior to the 2010 Oct outage. One wonders what the surveillance frequency is?  It must have blew past failing other surveillance frequencies and why the sensitivities this time? It is interesting the NRC never covered this issue with the approaching surveillance?

Grand Gulf's new NRC inspection report

"The team conducted a walkdown of the Division II emergency diesel generator room as their inspection. When walking down the perimeter of the diesel generator, the inspectors noted a large puddle of lube oil on the floor on the engine end of the machine near the lube oil filter. The puddle of lube oil contained saturated pads, which had been previously placed to contain the oil. These pads had been overburdened such that oil surrounded the pads.

The team identified that in 2009, a problem identification and resolution team reviewed this leakage on the Division II emergency diesel generator. The team presented a minor violation to the licensee as part of their exit for the licensee's failure to correct the lube oil sump leak on the Division II emergency diesel generator. The licensee entered this condition into their corrective action program as condition report CR-GGN- 2009-06385"...
Electricity declines 50 percent with shale boom

Posted on January 17, 2012 at 6:38 am by Bloomberg in Electricity, Energy demand

(Photo: AEI Services)

A shale-driven glut of natural gas has cut electricity prices for the U.S. power industry by 50 percent and reduced investment in costlier sources of energy.

With abundant new supplies of gas making it the cheapest option for new power generation, the largest U.S. wind-energy producer, NextEra Energy Inc. (NEE), has shelved plans for new U.S. wind projects next year and Exelon Corp. (EXC) called off plans to expand two nuclear plants. Michigan utility CMS Energy Corp. (CMS) canceled a $2 billion coal plant after deciding it wasn’t financially viable in a time of “low natural-gas prices linked to expanded shale-gas supplies,” according to a company statement.

Mirroring the gas market, electricity prices have dropped more than 50 percent on average since 2008, and about 10 percent during the fourth quarter of 2011, according to a Jan. 11 research report by Aneesh Prabhu, a New York-based credit analyst with Standard & Poor’s Financial Services LLC. Prices in the west hub of PJM Interconnection LLC, the largest wholesale market in the U.S., declined to about $39 per megawatt hour by December 2011 from $87 in the first quarter of 2008....


Decline in safety culture at Entergy Palisades nuclear power plant to be fixed

Friday Feb 14 message 2

[QUOTE who="Mike Mulligan"]Hmm, it is not the Detroit Free Press? [/QUOTE]

Wednesday Jan 4 message #7

"What is the difference in a NRC branch manager or project manager?

Did Jack (Jack Giessner NRC Branch chief ) say today Palisades is the worst performing plant in region III or was he saying it was the worst in his group of plant he controlled.

I think he said Palisades is the new worst performing plant in Region III?"

Michigan's Palisades nuclear plant may be named one of nation's 5 worst


The Palisades nuclear power plant, which sits on the shores of Lake Michigan, could soon be downgraded by the Nuclear Regulatory Commission to a status making it among the nation's five worst-performing nuclear plants after a year of accidents, unexpected shutdowns and safety violations.

(...What I was trying to highlight, was when I first mentioned the Detroit Free Press and when the Palisades article first came out of Jan 15th.) 
Transcipt quote from Feb 18, 2010:

"Actually, today is the first day that I have become concerned or fearful of the ramifications that are going around with Entergy and Palisades and Vermont Yankee and stuff."

Palisades Nuclear plant

1) 'Catch-22'  2.206 Petition
Transcripts from my presentation to the Petition Review Board

Feb 18, 2010 
Feb 23
April 9

2) 'Casablanca' 2.206 on Feb 22, 2011
You are chicken e-mail:
March 7, 2011

March 31

3) "Nothing Ever Matters" 2.206 NRC on Jan 10, 2012(tues 9:43pm)


...You are going to have to ask, how close is the design flow capacity of the service water pump to the minimum real tested flow capacity of the pump. Does it impart pump power and amps? What flow affects would happen in the riser if you had to bulk up the 40 foot shaft and the couplings?  Right, making the shaft and coupling larger would reduce the area in the impeller discharge riser and increase the resistance...head. I suspect it is a pumps design trade off with the increase radical area limiting flow to the area needed for the size of the coupling and shaft.

Remember the coupling and shaft sits in the impeller discharge flow.


...Just to show you how freaking sick the system is...the outcome of this is Entergy promised to hire the very same failed third party survey and investigation type company as what failed before. The whole issue of Entergy hiresing these guys and they generally dictates the outcome of the results. It would be better if was the NRC who choose and paid for these services. The whole idea that perpetrator of this preventable decline is the guy who chooses and controls the third party survey and investigator contractor results....it is riddled with blatant self interest.  It is a proven failed strategy in 2008-2009 and the whole lot of them is depending post Jan 11 to do again failure all over again... 

Jan 10 petition

"We are broadly are worried about in 2009 over the Palisades security falsification, in the outcome of the violations...whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over this very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip the most recent root cause Entergy admits there is deep and widespread safety cultural problems at the Palisades plant. I feel Palisades safety culture was in the pits in 2009 and before...and the (NRC ADR mandated 2008-2009 )cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution session over this, the Confirmatory Order, the Entergy (third party) investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy...the NRC created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them (by 2010). Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public’s eyes off fixing Entergy...where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up."

...Further...it is a grave corruption where with these engineering contractor service providers, the employee survey and culture investigation contractors....a company like Entergy will dictate the outcome of the contractor service provider before they are hired the invesigators. The job of the outside third party contractor is to come up or manufacture the plausible facts and evidence to fit the dictates of the corporations defined before even the investigation begins. It is the filler material before the artificial results of the so called and independent third party investigation.

That is why they fail over and over to change the results of the nuclear plant behavior like Palisades...

They are all great gamers!